Environmental Compliance using CEMS

Environmental Compliance using CEMS ERM s Exton Office March 13, 2012 Joel Millard Environmental Regulatory Specialist.1

Overview CEMS Why install a CEMS Common Analyzer Types MATS Compliance using CEMS DAHS Compliance tool Reporting tool MATS Compliance using DAHS.2

Why Install CEMS? Permit Requirement New Environmental Regulations Real Time Data for Air Pollution Control (APC) device operation Closed Loop Environmental Control (CLEC) NO X analyzer at the inlet to an SCR SO 2 analyzer at the inlet to an FGD Coal Fire Detection System Monitors the CO and O 2 concentrations of coal storage piles as an early detection system for fires.3

Possible Timeline for Environmental Regulatory Requirements for the Utility Industry Ozone (O 3 ) SO x /No x Visibility CSAPR Cross State Air Pollution Rule Water PM/PM 2.5 Ash MATS CO 2 Revised Ozone NAAQS CAIR Vacated CAIR Remanded Begin CAIR Phase I Seasonal NO x Cap NO 2 Primary NAAQS Transport Rule proposal issued (CAIR Replacement) SO 2 Primary NAAQS CO 2 Regulation (PSD/BACT) CSAPR Final Rule Released (CAIR Replacement) Effluent Guidelines proposed rule expected SO X /NO X Secondary NAAQS 316(b) final rule expected Effluent Guidelines Final rule expected PM Transport Rule 316(b) Compliance 3-44 yrs after final rule Effluent Guidelines Compliance 3-53 5 yrs after final rule 08 09 10 11 12 13 14 15 16 17 CAMR and Delisting Rule Begin CAIR Vacated Phase I Annual SO 2 Cap Begin CAIR Phase I Annual NO x Cap Chart Modified from: MATS Proposed Rule Proposed Rule for CCRs Mgmt 316(b) proposed Rule MATS Final Rule Next PM- 2.5 NAAQS Revision CSAPR - Phase I Reductions - Stayed by Court - Delayed from start of 2012, perhaps by one year Final Rule for CCRs Mgmt Next Ozone (Expected late NAAQS 2012) Revision CSAPR - Phase II Reductions - Stayed by Court, delayed perhaps one year MATS Compliance 3 yrs after final rule Clean Air Visibility Rule (BART) Begin Compliance Requirements under Final CCR Rule (ground water monitoring, double liners, closure, dry ash conversion).4

Continuous Emission Monitoring System US EPA Definition of a CEMS The total equipment used to acquire data, which includes sample extraction hardware, analyzers, data recording and processing hardware, and software..5

Two Main Types of CEMS Dry Extractive Non corrosive gas streams Main components Sample probe (usually heated) Heated sample line Sample pump Gas conditioner (moisture removal) Analyzers Dilution Extractive Corrosive Gas streams Main components Sample probe Dilution orifice Dilution air system Sample line Sample pump Analyzers.6

Common Analyzer Types and Technologies Oxides of Nitrogen (NO X ) Chemiluminescense with an NO 2 to NO converter Sulfur Dioxide (SO 2 ) Ultraviolet (UV), Non-dispersive infrared (NDIR), Fluorescence Diluent Gas (O 2 /CO 2 ) O 2 paramagnetic or zirconium oxide sensor CO 2 infrared Carbon Monoxide (CO) Gas Filter Correlation Volatile Organic Compounds (VOC) Flame Ionization Detector (FID), Gas Chromatograph (GC) Stack Flow Ultrasonic, Differential Pressure ( P) Opacity (COMS) Single or double pass Transmissometry.7

Mercury and Air Toxics Standards (MATS) 40 CFR Part 63, Subpart UUUUU National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Also known as the Utility MACT Final rule published in the Federal Register on February 16, 2012 Effective 60 days from publishing in FR (April 16, 2012) Affected sources have 3 years from this date to become compliant* *note: it appears that the EPA will grant a one year extension for sources that are showing an effort to achieve compliance.8

Timeline for Compliance Mercury and Air Toxics Standard (MATS) Covers Filterable Particulate Matter as a marker for heavy metals, HCl or SO 2 as a marker for acid gasses, and Mercury 2012 State Extensions Available 2017 2012 2013 2014 2015 2016 2017 Rule published in Federal Register Compliance Begins.9

UMACT CEMS Additions Added Measurements & Data Collection PM CEMS Filterable only ( OR non Hg metals) SO 2 or HCl (If SO 2 does not meet limit) Hg CEMS or Sorbent Traps Parametric Monitoring Depends on Control device Limits based on 30 boiler day rolling average.10

Particulate Matter (PM).11

UMATS PM Limits EGU Category PM Total Non Hg HAPS Metals Existing Units lbs/mmbtu mg/scm lbs/mmbtu mg/scm Coal (Not Low) 0.03 49.1 0.00005 0.1 Coal (Low Rank) 0.03 49.1 0.00005 0.1 IGCC 0.04 65.5 0.00006 0.1 Liquid Oil Cont. 0.03 52.3 0.0008* 1.4 Solid Oil (Coke) 0.008 13.1 0.00004 0.1 NEW Units Lbs/MWh mg/scm Lbs/MWh mg/scm Coal (Not Low) 0.007 1.1 0.00006 0.01 Coal (Low Rank) 0.007 1.1 0.00006 0.01 IGCC 0.07 11.1 0.0004 0.06 Liquid Oil Cont. 0.07 NA 0.0002* 0.03 Solid Oil (Coke) 0.02 3.2 0.0006 0.10 * Includes Hg PM.12

PM Compliance Options 1. Measure using PM CEMS 2. Measure using a Continuous Parametric Monitoring System (CPMS) and perform annual compliance testing 3. Quarterly testing for PM/Non-Hg Hap Metals PM filterable Method 5 test - $14K Total HAP Metals Method 29 train - $15K/quarter Individual HAP Metals (10) - More $$ than Method 29 test NOTE: Annual Compliance test not required for Option 3.13

PM CEMS Permissible Monitor Types for UMACT Compliance Light Scatter Scintillation Beta Attenuation Mass Accumulation Back Scatter Extractive Beta Gauge Extractive Back Scatter In Situ.14

Model Type Wet Stack PM Model Types Capital Cost O&M Cost SICK SP100 Light Scatter $ $ Insitu SICK FWE 200 Light Scatter X $$ $$ Extractive TML LaserHawk Light Scatter $ $ Insitu MSI BetaGuage Beta X $$$ $$$ Extractive PCME 181 Light Scatter X $$ $$ Extractive Durag D R 300 Light Scatter $ $ Notes Preciptech CPM Scintillation $ $ CPMS/Leak Detector Note: Thermo hybrid PM CEMS Not commercially available..15

PM CEMS Certification PM CEMS must initially be certified in accordance with 40 CFR Part 60, Appendix B, Performance Specification 11 Test to generate a correlation curve between the particulate concentration and the unit load Requires at least 15 Paired samples 3 loads, 5 runs per loading level usually requires more than the minimum number of runs Tests are time consuming and expensive (35k-50k), and often cause problems with the state regulatory agency Ongoing QA/QC procedures outlined in 40 CFR 60, Appendix F, Procedure 2 Absolute Correlation Audit (ACA) Challenge the analyzer with three filters Response Correlation Audit (RCA) - Basically 12 run PS -11 Relative Response Audit (RRA) 3 particulate tests, normal load.16

CPMS MATS requires the same analyzer technology as a PM CEMS Analyzer does not require certification Compliance based on annual stack test results Parametric data recorded during annual compliance tests A parameter range is determined during the annual testing Unit is deemed compliant as long as the CPMS is operating within this range.17

PM CEMS vs. CPMS UMATS allows for EITHER PM CEMS OR CPMS Both technologies must use Light Scatter, Scintillation, Beta Attenuation, or Mass Accumulation What is the Difference? CPMS Not a certified PM CEMS Similar technology Parametric limit is determined from annual testing PM CEMS Initial capital cost & testing is more $$ PM CEMS Exempt from Opacity monitoring (Pending state approval).18

HCL Compliance CL H.19

UMATS HCl/SO2 Limits EGU Category HCl SO2 * Existing Units lbs/mmbtu ppm@ 3% O2 lbs/mmbtu ppm@ 3% O2 Coal (Not Low) 0.002 1.9 0.2 105.5 Coal (Low Rank) 0.002 1.9 0.2 105.5 IGCC 0.0005 4.9 NA NA Liquid Oil Cont. 0.0002 2.0 NA NA Solid Oil (Coke) 0.005 4.6 0.3 158.3 NEW Units Lbs/GWh Lbs/GWh Coal (Not Low) 0.4 0.04 0.4 20.5 Coal (Low Rank) 0.4 0.04 0.4 20.5 IGCC 2 0.2 0.4 20.5 Liquid Oil Cont. 0.4 0.04 NA NA Solid Oil (Coke) 0.4 0.04 0.4 20.5 * SO2 Limit only for units with FGD.20

Compliance Options Continuously monitor HCL concentrations Continuously monitor SO 2 concentrations Coal fired sources already have SO 2 analyzers installed Requires that the source has a wet or dry FGD Once a plant opts in to using SO2 as a surrogate, the 0.20 lb/mmbtu limit becomes federally enforceable some clients choosing not to use this option, due to the reduction of fuel flexibility.21

HCL Limit is 0.002 lbs/mmbtu (~1.9 ppm) Coal fired units Initial and Annual testing Method 26 or 26A Annual compliance tests are $14K 3 1 hour runs HCl CEMS types: FTIR Hot, wet extractive TDL In-situ, cross stack/duct Gas Filter Correlation Infra-red (GFC) Hot, wet extractive New probes/ports required for most applications HCl CEMS have been in use for many years on waste incinerator applications.22

Fourier Transform Infrared Extractive, Hot, wet CEMS System consists of: Rack mounted analyzer Heated Sample Line IR Source Long path gas cell Inferometer HCl - FTIR Detector creates interferogram of sample stream Issues HCl sample stream losses H2O interference, probe pluggage Slow response Setup and calibration Software ease of use Lack of an EPA Performance Specification.23

FTIR Extractive System 181 C Heated Sample Line Back Flush Air Teflon or Glass coated tubing Instrument Air Supply Heated Sample Probe Sample Gas Calibration Gas FTIR Analyzer Inferometer Gas Cell Stack Heated Sample Pump Computer: FTIR SW Exhaust Manifold Probe Material: Hastelloy or Inconel Heated Sample Oven Pressure Regulator Cal Gas Typical Hot/Wet Sample Conditioning System.24

TDL Tunable Diode Laser Utilizes an in situ IR analytical technique Advantages Highly Selective Measure low concentrations Eliminate cross-interference Single digit measurement Fast response Disadvantages Can t monitor multiple parameters Difficult to calibrate on the stack Calibration standards unavailable Difficult to keep aligned Vibrations cause problems.25

Typical TDL Cross Stack Configuration Transmitter Flanges Receiver Detector Window Purge Cell Laser Calibration Cell Process Gas.26

In-Situ Methods & Issues Path length & particulate densities affect accuracy Limitations on stack gas temperatures Measurement must be temperature & path length corrected Issues: Speciation and cross-interference Vibration, alignment high velocities Inability to be challenged with calibration gas.27

Mercury Compliance.28

UMATS Hg Limits EGU Category Hg Existing Units Lbs/tBTU ug/scm Coal (Not Low) 1.2 1.97 Coal (Low Rank) 4.0 6.50 IGCC 2.5 4.81 Liquid Oil Cont. 0.05 0.09 Solid Oil (Coke) 0.2 0.33 NEW Units Lbs/GWh Coal (Not Low) 0.0002 0.03 Coal (Low Rank) 0.04 6.30 IGCC 0.003 0.56 Liquid Oil Cont. 0.0001 0.02 Solid Oil (Coke) 0.002 0.32.29

Hg Compliance Options Continuous Monitors must be installed Two technologies currently available Hg analyzer Continuous Sorbent Trap Monitoring System Sorbent Trap System.30

Hg Monitoring Technology Comparison Both Hg CEMS and Sorbent trap are certified using Method 30B Hg CEMS have continuous data Sorbent trap gives weekly updates (5-7 days) Sorbent trap is lower capital cost O&M costs for each similar Hg CEMS may be higher maintenance for some applications Control Device for Hg is a factor in deciding continuous vs. sorbent trap.31

Hg Monitoring - Cost Comparison $K Hg CEMS Hg Sorbent Trap Capital 220 90 Installation 100 49 1 st year O&M 30 37 Total 350 177 Notes: 1.Certification costs are equivalent 2.Annual certification test costs are similiar 3.Sample Line costs are excluded 4.Cost of air compressor for Hg CEMS should also be considered 5.Sorbent trap need easy access to probe location.32

Hg CEMS Typical design is a dilution extractive system Analyzer measures elemental Hg Measurement levels are extremely low - ppt Ionic Hg is converted to elemental Hg Hg CEMS are more complex than conventional CEMS Capital, installation, and O&M costs are higher Alternative to Hg CEMS is Sorbent Trap System (non-continuous).33

Stack Inertial Probe Hg CEMS - Integrated Design Eductor Air Air Cleanup Panel Instrument Air Supply Regulatory Database DAHS Cal Gas Port (NIST traceable) HgCl2 Cal Gas Unit Dilution Module Sample Dilution Air Heated Teflon Sample Extraction Line Blowback Air (heated) (convert Hg +2 to Hg 0 ) Thermal Catalyst DI water injection Elemental Mercury Calibration Line Chiller Cooling Air & Cal Gas Sample Dilution Air Bypass vent PLC Mercury Analyzer Elemental Mercury Calibration Unit CEMS Flow Data Vent DI water discharge (works on partial pressures of Hg) Carrier Gas.34

Hg Sorbent traps Can be used instead of CEMS measurement & also for ref. Method stack tester Uses dual train carbon traps mounted in tip of probe in stack Hg is collected on carbon traps and sent to lab for Hg analysis (every 5-7 days) Must measure sample flow, stack flow, and stack conditions Issues: Loose 5-7 days of data if traps fail QA tests Hg reading are batch sample I.e. Non-Continuous.35

Typical Sorbent Trap Monitoring System Paired trains required Two traps Two Sample paths.36

Summary Particulate Matter PM CEMS CPMS and Annual Testing Quarterly testing for PM or Non-Hg HAP Metals Hydrogen Chloride FTIR - More accurate but more expensive TDL- Cheaper and easier to integrate, may have some issues with data accuracy Mercury Mercury CEMS - Costlier method, however real time data is available Sorbent Trap System - Cheaper method, however data is not available and it is more labor intensive for the plant personnel.37

CEMS Questions?.38

Data Acquisition and Handling System Place to view, store, and reduce data from the CEMS Can receive data directly from the analyzers serially, by ethernet, or via analog 4-20ma signals Can also get an already calculated concentration/rate that is calculated externally (PLC) Helps to ensure compliance through a series of alarms and episodes.39

General Data Acquisition Diagram CEMS ANALYZERS Optional Operator Interface Terminal PLC PLANT INPUTS DCS PANEL METERS, ANNUNCIATORS, ETC..40

DAHS Functions Data Validation Data Reduction uses pre-programmed formulas to reduce the data to the proper engineering units ppm @ 15% O2 lb/hr lb/mmbtu TPY lb/mwhr lb/tons of clinker Compliance Tool Data Reporting.41

Data Validation Determines if a valid hourly average can be calculated based on: Calibrations did they pass, has one been performed? Number of valid minutes in the hour Faults Operating mode of the Unit - SUSDMALF.42

Calibration Criteria Part 60 vs. Part 75 Part 60 Pass/Fail >5% of span for 5 consecutive days > 10% of span once Frequency Must be performed daily(24 hours) Part 75 Pass/Fail >2.5% of span for gaseous analyzers > 3.0% of span for flow monitors Frequency must be performed once every 26 online hours.43

Using Your DAHS to Track Compliance Each permit limit set up as an episode Alarms can be configured to warn users of an episode Real time display and historical trending screens Most DAHS packages are able to apply the required data substitution for periods of missing data.44

Alarms History.45

Real Time (Display).46

Trending Screen (Historical Trend Screen).47

DAHS Reporting Various Types of Reports Can be Configured on a DAHS QA/QC Audit reports calibration drift, CGA, Linearity, RATA Episode list report list of all permit limit exceedances CEMSUM report report that lists online time, periods of unit start up/ shut down and the % availability for each analyzer State specific reports that are configured on a project by project basis Federally Required Electronic Data Reports (EDR) Some DAHS packages can automatically create Part 75 required EDR files for the user to upload the EPA s Emission Compliance and Monitoring Plan System (ECMPS).48

MATS Data Reporting Sources will be required to submit HCL/SO2 and Hg CEMS data to the EPA via ECMPS DAHS should be able to add these data and certification elements to the sources XML EDR file for upload.49

Thank You Questions? jkmillard@babcock.com 215 997 4212.50